DOCSLIB.ORG

Download Global Tax Weekly

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text

Load more

GLOBAL TAX WEEKLY ISSUE 40 | AUGUST 15, 2013 a closer look SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL FISCAL GOVERNANCE BUDGETS COMPLIANCE OFFSHORE SECTORS MANUFACTURING RETAIL/WHOLESALE INSURANCE BANKS/FINANCIAL INSTITUTIONS RESTAURANTS/FOOD SERVICE CONSTRUCTION AEROSPACE ENERGY AUTOMOTIVE MINING AND MINERALS ENTERTAINMENT AND MEDIA OIL AND GAS COUNTRIES AND REGIONS EUROPE AUSTRIA BELGIUM BULGARIA CYPRUS CZECH REPUBLIC DENMARK ESTONIA FINLAND FRANCE GERMANY GREECE HUNGARY IRELAND ITALY LATVIA LITHUANIA LUXEMBOURG MALTA NETHERLANDS POLAND PORTUGAL ROMANIA SLOVAKIA SLOVENIA SPAIN SWEDEN SWITZERLAND UNITED KINGDOM EMERGING MARKETS ARGENTINA BRAZIL CHILE CHINA INDIA ISRAEL MEXICO RUSSIA SOUTH AFRICA SOUTH KOREA TAIWAN VIETNAM CENTRAL AND EASTERN EUROPE ARMENIA AZERBAIJAN BOSNIA CROATIA FAROE ISLANDS GEORGIA KAZAKHSTAN MONTENEGRO NORWAY SERBIA TURKEY UKRAINE UZBEKISTAN ASIA-PAC AUSTRALIA BANGLADESH BRUNEI HONG KONG INDONESIA JAPAN MALAYSIA NEW ZEALAND PAKISTAN PHILIPPINES SINGAPORE THAILAND AMERICAS BOLIVIA CANADA COLOMBIA COSTA RICA ECUADOR EL SALVADOR GUATEMALA PANAMA PERU PUERTO RICO URUGUAY UNITED STATES VENEZUELA MIDDLE EAST ALGERIA BAHRAIN BOTSWANA DUBAI EGYPT ETHIOPIA EQUATORIAL GUINEA IRAQ KUWAIT MOROCCO NIGERIA OMAN QATAR SAUDI ARABIA TUNISIA LOW-TAX JURISDICTIONS ANDORRA ARUBA BAHAMAS BARBADOS BELIZE BERMUDA BRITISH VIRGIN ISLANDS CAYMAN ISLANDS COOK ISLANDS CURACAO GIBRALTAR GUERNSEY ISLE OF MAN JERSEY LABUAN LIECHTENSTEIN MAURITIUS MONACO TURKS AND CAICOS ISLANDS VANUATU GLOBAL TAX WEEKLY a closer look Global Tax Weekly – A Closer Look Using the unrivalled worldwide multi-lingual research Alongside the news analyses are a wealth capabilities of leading law and tax publisher Wolters of feature articles each week covering key Kluwer and its new acquisition BSI (The Lowtax current topics in depth, written by a team of Network), CCH publishes Global Tax Weekly –– A senior international tax and legal experts and Closer Look (GTW) as an indispensable up-to-the- supplemented by commentative topical news minute guide to today's shifting tax landscape for all analyses. Supporting features include a round-up tax practitioners and international fi nance executives. of tax treaty developments, a report on important new judgments, a calendar of upcoming tax Topicality, thoroughness and relevance are our conferences, and “The Jester's Column,” a light- watchwords: BSI's network of expert local researchers hearted but merciless commentary on the week's covers 130 countries and provides input to a US/UK tax events. team of editors outputting 100 tax news stories a week. GTW highlights 20 of these stories each week Read Global Tax Weekly –– A Closer Look in under a series of useful headings, including industry printable PDF form, on your iPad or online through sectors (e.g. manufacturing), subjects (e.g. transfer Intelliconnect, and you'll be a step ahead of your pricing) and regions (e.g. asia-pacifi c). world on Monday morning! GLOBAL TAX WEEKLY ISSUE 40 | AUGUST 15, 2013 a closer look CONTENTS FEATURED ARTICLES Dutch Flow-Th rough Entities In Th e Finance Act 2013 Introduces Th e UK’s Netherlands: An Economic Impact Analysis New Statutory Residence Test by Prof. dr. Gerard T.K. Meussen, Professor of tax law by David Klass and Janice Houghton, Gide Loyrette at the Radboud University Nijmegen, the Netherlands Nouel LLP 32 and technical advisor to BDO Tax Consultants, Tilburg, the Netherlands 5 OECD Project On Intangibles: Revised Discussion Draft Released Th e Rising Tide Of Tax In France by PricewaterhouseCoopers 36 by Stuart Gray, Senior Editor, Global Tax Weekly 9 Topical News Briefi ng: Th e Double-Edged Tax And Th e Treasury Center: Sword Of Park’s Tax Policy Cash Management And Cash Pooling by the Global Tax Weekly Editorial Team 42 by Mark Minihane, Associate Partner, International Tax Services, Ernst & Young LLP, Birmingham, UK 26 Tax News From Th e Middle East by KPMG Partners In Th e Region 43 Topical News Briefi ng: Bolting Th e Door To A Carbon Tax Australian Elections: Assessing Th e Parties’ by the Global Tax Weekly Editorial Team 31 Tax Plans by Stuart Gray, Senior Editor, Global Tax Weekly 47 NEWS ROUND-UP Country Focus: South Korea 55 Off shore 59 South Korea To Finalize Property Tax Changes Off shore Company Formations Have Slowed South Korea Introduces 2013 Tax Bill Gibraltar Border Tax Row Escalates South Korea Government’s Tax Policies Under Fire Hong Kong’s Advantages Promoted In New Zealand Bermuda, US Treasury Complete FATCA Negotiations Jersey To Submit To New Regulations On EU Savings Tax Country Focus: United States 63 Regional Focus: Africa 72 House Passes Anti-US Carbon Tax Amendment South African Business Warns Over New Carbon Tax US Study Criticizes Increased CGT Rates US Discusses Future African Trade Initiatives IRS Disputes Tyco Debt Interest Deductions Amended Customs Bills Submitted To SA Parliament US Expats Giving Up Passports To Avoid Tax Obligations Morocco Confi rms Large Farms To Lose Tax Exemption US Treasury Releases 2013-14 Tax Guidance Plan TAX TREATY ROUND-UP 76 SMEs 69 CONFERENCE CALENDAR 78 IMF Addresses Japanese Consumption Tax Dilemma IN THE COURTS 96 Bulgaria To Launch Cash Accounting Option THE JESTER'S COLUMN 101 US Small Businesses Pay Highest Tax Rates Th e unacceptable face of tax journalism For article guidelines and submissions, contact [email protected] FEATURED ARTICLES ISSUE 40 | AUGUST 15, 2013 Dutch Flow-Through Entities In The Netherlands: An Economic Impact Analysis by Prof. Dr. Gerard T.K. Meussen, Professor of tax law at the Radboud University Nijmegen, the Netherlands and technical advisor to BDO Tax Consultants, Tilburg, the Netherlands Commissioned by Holland Financial Center The survey expresses that the Netherlands is a (HFC), the Amsterdam based SEO research tax-wise attractive location for the establish- group researching the economic value of tax ment of flow-through entities. Not so much structures of foreign companies in the Nether- because of the applicable corporate income tax lands. 1 Th e Holland Financial Center foundation rate (which is reasonable in respect of global tax is a public-private initiative set up by organiza- rates) but because of the absence of source taxa- tions from throughout the fi nancial sector, the tion on interest and royalty payments and the government and regulators. Th ey include banks, vast (98) bilateral treaty network. It should be insurers, trading fi rms, pension funds, asset man- kept in mind that the absence of source taxa- agers, audit fi rms, law fi rms and the government. tion in the Netherlands is not something new, As a joint venture, the purpose of the Holland but that it already exists for many decades. Fur- Financial Center is to strengthen the fi nancial thermore there is a genuine willingness of the sector in the Netherlands . Netherlands tax administration to issue tax rul- ings in order to give entities established in the Th e study took place after questions from the Netherlands legal certainty about their present House of Representatives to Secretary of Finance or future tax position. Frans Weekers and a series of articles called "Tax Route Netherlands" in Het Financieele Dagblad According to the survey, in the year 2010 there in the years 2011 and 2012. Th e study includes were approximately 12,000 special fi nancial insti- the special fi nancial institutions (also referred to tutions (entities) established in the Netherlands. as letter box companies or SPVs 2 ) and non-bank Th e dividend, interest and royalty fl ows in 2010 fi nancing (known as shadow banking). Th e term amounted to a total of around EUR153bn (in- letterbox is used in this research for companies that coming) and EUR125bn (outgoing). Dividends are, for tax reasons, without signifi cant commer- are here the dominant power, with 70 percent and cial or operational presence in the Netherlands. 60 percent of the total, respectively. 5 Of the 12,000 entities in the Netherlands there are on the other hand this also makes a substantial con- more than 5,000 belonging to a cluster – compa- tribution to the Netherlands economy. nies that are part of the same group. Taking these clusters into consideration, according to the re- However, the study provides no evidence for the search about 8,500 multinationals have established assertion of the Netherlands State Secretary of Fi- their fi nances through the Netherlands by means of nance Weekers, that fi nancial SPVs of foreign cor- one or more SPVs. Special purpose entities contrib- porations settled in the Netherlands eventually ute according to the survey an estimated amount grow into a headquarters or distribution center. of EUR3 to EUR3.4bn a year to the Netherlands economy in the form of taxes, labor and services Politically sensitive is the conclusion of the re- purchased as business services. Of this amount, ac- search group that developing countries, as a re- cording to the researchers, EUR1.2bn relates to the sult of tax treaties with the Netherlands, based on payment of corporation tax. In addition, SPVs, as a rough estimate in the year 2011, are forgoing part of that EUR3 to EUR3.4 bn per year in 2011, approximately EUR145m in tax revenues every according to the researchers paid EUR1bn dividend year. Here according to researchers various nu- withholding tax. Th e latter, however is questioned ances have to be taken into consideration, such as by the tax world as SPVs are set to up to avoid divi- the fact that developing countries can also benefi t dend withholding tax. from tax treaties. It is fairly obvious that politi- cians will ask for more research on the topic of Th us SPVs are providing (directly and indirectly) developing countries. A lot of politicians at least according to the researchers, employment of around fi nd it unethical to use bilateral tax treaties in a 8,800 to 13,000 jobs (FTEs).
Recommended publications
  • The New 39% Tax Rate: What Happens Now?

    The New 39% Tax Rate: What Happens Now?

    Tax Tips Alert | 3 December 2020 The new 39% tax rate: what happens now? On Wednesday afternoon, the Government introduced a new tax bill to Parliament under urgency, which proposes a 39% tax rate on individual income over $180,000. Given Labour’s majority in Parliament, the bill is almost With the new income tax rate, many other changes guaranteed to be passed and will be effective for the need to be made to tax legislation. This will ensure start of the 2022 income tax year. the new rate does not create distortions across the taxation of other types of personal income. The other This new rate could form part of New Zealand’s rate changes are to the: progressive tax system for years to come as the Government navigates an economic recovery, • Fringe benefit tax: The rate on amounts of commitments to public services, and budgets to service all inclusive pay over $129,681 will be 63.93% the forecast growth in Government debt. The last top to ensure consistent treatment of cash and marginal rate change was on 1 October 2010, when the non‑cash remuneration. This threshold differs from Government reduced the rate from 38% on income over the income tax threshold because it is calculated $70,000 to 33%, where it has remained since. on the after‑tax value of non‑monetary benefit i.e. taking into account PAYE which would otherwise The 2010 change harmonised the top personal rate have been paid. with the trustee rate. As those rates once again diverge, we expect to see more housekeeping and restructuring • Employer’s superannuation contribution tax and activity in advance of 1 April 2021.
  • To View a PDF of This Article, Please Click Here

    To View a PDF of This Article, Please Click Here

    GLOBAL TAX WEEKLY ISSUE 134 | JUNE 4, 2015 a closer look SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL FISCAL GOVERNANCE BUDGETS COMPLIANCE OFFSHORE SECTORS MANUFACTURING RETAIL/WHOLESALE INSURANCE BANKS/FINANCIAL INSTITUTIONS RESTAURANTS/FOOD SERVICE CONSTRUCTION AEROSPACE ENERGY AUTOMOTIVE MINING AND MINERALS ENTERTAINMENT AND MEDIA OIL AND GAS COUNTRIES AND REGIONS EUROPE AUSTRIA BELGIUM BULGARIA CYPRUS CZECH REPUBLIC DENMARK ESTONIA FINLAND FRANCE GERMANY GREECE HUNGARY IRELAND ITALY LATVIA LITHUANIA LUXEMBOURG MALTA NETHERLANDS POLAND PORTUGAL ROMANIA SLOVAKIA SLOVENIA SPAIN SWEDEN SWITZERLAND UNITED KINGDOM EMERGING MARKETS ARGENTINA BRAZIL CHILE CHINA INDIA ISRAEL MEXICO RUSSIA SOUTH AFRICA SOUTH KOREA TAIWAN VIETNAM CENTRAL AND EASTERN EUROPE ARMENIA AZERBAIJAN BOSNIA CROATIA FAROE ISLANDS GEORGIA KAZAKHSTAN MONTENEGRO NORWAY SERBIA TURKEY UKRAINE UZBEKISTAN ASIA-PAC AUSTRALIA BANGLADESH BRUNEI HONG KONG INDONESIA JAPAN MALAYSIA NEW ZEALAND PAKISTAN PHILIPPINES SINGAPORE THAILAND AMERICAS BOLIVIA CANADA COLOMBIA COSTA RICA ECUADOR EL SALVADOR GUATEMALA PANAMA PERU PUERTO RICO URUGUAY UNITED STATES VENEZUELA MIDDLE EAST ALGERIA BAHRAIN BOTSWANA DUBAI EGYPT ETHIOPIA EQUATORIAL GUINEA IRAQ KUWAIT MOROCCO NIGERIA OMAN QATAR SAUDI ARABIA TUNISIA LOW-TAX JURISDICTIONS ANDORRA ARUBA BAHAMAS BARBADOS BELIZE BERMUDA BRITISH VIRGIN ISLANDS CAYMAN ISLANDS COOK ISLANDS CURACAO GIBRALTAR GUERNSEY ISLE OF MAN JERSEY LABUAN LIECHTENSTEIN MAURITIUS MONACO TURKS AND CAICOS ISLANDS VANUATU GLOBAL TAX WEEKLY a closer look Global Tax Weekly – A Closer Look Combining expert industry thought leadership and team of editors outputting 100 tax news stories a the unrivalled worldwide multi-lingual research week. GTW highlights 20 of these stories each week capabilities of leading law and tax publisher Wolters under a series of useful headings, including industry Kluwer, CCH publishes Global Tax Weekly –– A Closer sectors (e.g.
  • Lexis® PSL Tax Analysis

    Lexis® PSL Tax Analysis

    Lexis ® PSL Analysis Tax Lexis ® PSL Tax Analysis Autumn Statement 2016 – views from the market Tax analysis: Views from leading tax practitioners on Autumn Statement 2016. The Lexis®PSL Tax Consulting Editorial Board (CEB) and other leading tax practitioners provide us with their views on the Autumn Statement delivered by the Chancellor on 23 November 2016. For the Lexis®PSL Tax summary and analysis of the key business tax announcements in Autumn Statement 2016, see: Autumn Statement 2016—Lexis®PSL Tax analysis. Overall views of the Autumn Statement 2016 on the following topics: AUTUMN STATEMENT 2016 IN OVERVIEW BUSINESS AND ENTERPRISE NON-RESIDENT COMPANIES SUBSTANTIAL SHAREHOLDING EXEMPTION EMPLOYMENT TAXES INSURANCE PRIVATE EQUITY AND FUNDS STAMP TAXES REAL ESTATE VAT AND INDIRECT TAXES OIL AND GAS TAX AVOIDANCE AND EVASION TAX ADMINISTRATION AND COMPLIANCE LexisPSL Tax Analysis | Get a free trial of LexisPSL Tax at lexisnexis.co.uk/AS2016/viewsfromthemarket Tax - views Tax from the market Lexis ® PSL AUTUMN STATEMENT 2016 IN OVERVIEW Gerald Montagu, NGM Tax Law and CEB member—Business, theatrical performance is a thing of the past, and we must now the Chancellor recognises, dislikes uncertainty and in his first get used to a more understated air. Or to put it another way, the (and, we were told, the last) Autumn Statement, some elements speech was not very interesting: Tigger replaced by Eeyore. of the approach he intends to take in pursuit of greater certainty The Chancellor confirmed that we will be getting a BEPS-inspired became just a little bit clearer. restriction on the deductibility of corporate debt costs to 30% A measure of caution seems to be an important element of of adjusted EBITDA, and reform of the corporate loss relief rules.
  • Relationship Between Tax and Price and Global Evidence

    Relationship Between Tax and Price and Global Evidence

    Relationship between tax and price and global evidence Introduction Taxes on tobacco products are often a significant component of the prices paid by consumers of these products, adding over and above the production and distribution costs and the profits made by those engaged in tobacco product manufacturing and distribution. The relationship between tax and price is complex. Even though tax increase is meant to raise the price of the product, it may not necessarily be fully passed into price increase due to interference by the industry driven by their profit motive. The industry is able to control the price to certain extent by maneuvering the producer price and also the trade margin through transfer pricing. This presentation is devoted to the structure of taxes on tobacco products, in particular of excise taxes. Outline Tax as a component of retail price Types of taxes—excise tax, import duty, VAT, other taxes Basic structures of tobacco excise taxes Types of tobacco excise systems Tax base under ad valorem excise tax system Comparison of ad valorem and specific excise regimes Uniform and tiered excise tax rates Tax as a component of retail price Domestic product Imported product VAT VAT Import duty Total tax Total tax Excise tax Excise tax Wholesale price Retail Retail price Retail & retail margin Wholesale Producer Producer & retail margin Industry profit Importer's profit price CIF value Cost of production Excise tax, import duty, VAT and other taxes as % of retail price of the most sold cigarettes brand, 2012 Total tax
  • Alcohol Taxation in Australia

    Alcohol Taxation in Australia

    Alcohol taxation in Australia Report no. 03/2015 © Commonwealth of Australia 2015 ISBN 978-0-9925131-9-1 (Online) This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivs 3.0 Australia License. The details of this licence are available on the Creative Commons website: http://creativecommons.org/licenses/by-nc-nd/3.0/au/ Use of the Coat of Arms The terms under which the Coat of Arms can be used are detailed on the following website: www.itsanhonour.gov.au/coat-arms Produced by: Parliamentary Budget Office Designed by: Studio Tweed Assistant Parliamentary Budget Officer Revenue Analysis Branch Parliamentary Budget Office Parliament House PO Box 6010 CANBERRA ACT 2600 Phone: (02) 6277 9500 Email: [email protected] Contents Foreword _______________________________________________________________ iv Overview ________________________________________________________________ v 1 Introduction __________________________________________________________ 1 2 Alcohol taxation receipts _______________________________________________ 1 3 Australia’s system of alcohol taxation _____________________________________ 2 4 Recent history of alcohol taxation ________________________________________ 9 5 Conclusion __________________________________________________________ 10 Appendix A—Discretionary changes in excise rates since 1 January 2000 ____________ 11 References ______________________________________________________________ 14 iii Foreword This report examines the structure of alcohol taxation in Australia. The arrangements for taxing alcohol in Australia are complex and have evolved over many years. Alcohol is taxed on either a volume or a value basis, with a range of effective tax rates applying depending on the type of beverage and packaging, alcohol strength, place of manufacture and the method or scale of production. Consistent with the PBO’s mandate, the report presents a factual analysis and does not include policy recommendations. It is intended to help inform discussion of this important public policy issue.
  • The Changing Distribution of Federal Taxes: 1975-1990

    The Changing Distribution of Federal Taxes: 1975-1990

    The Changing Distribution of Federal Taxes: 1975-1990 CONGRESSIONAL BUDGET OFFICE U.& CONGRESS WASHINGTON, OC. 20515 ERRATA The Changing Distribution of Federal Taxes: 1975 -1990 October 1987 The attached five pages represent corrections to details in the ref- erenced published CBO report. Readers may wish to detach the sheets and insert them at the appropriate places in the bound report. at page 42 Figure 5. Effective Federal Tax Rates by Population Decile (All taxes combined) Corporate Taxes Allocated Corporate Taxes Allocated to Capital Income to Labor Income 40 1977 Tax Law 1984 Tax Law 1988 Tax Law •? 30 1 !- i £ 10 i I 1234567 8 g 10 * - 123456789 10* Population Daciles H- *— Population Diciles *- SOURCE: Congressional Budget Office tax simulation models. NOTE: Families are ranked by the size of family income. Because family income includes the family's share of the corporate income tax, the ordering of families depends on the allocation of corporate taxes The lowest decile excludes families with zero or negative incomes. The effective tax rate is the ratio of taxes to family income in each income class. CHAPTER VI THE EFFECT OF TAX LAW CHANGES 59 TABLE 11. EFFECTIVE FEDERAL TAX RATES, BY POPULATION DECILE, WITH CONSTANT 1988 INCOMES: CORPORATE INCOME TAX ALLOCATED TO CAPITAL INCOME Individual Social Corporate Income Insurance Income Excise All Decile a/ Tax Taxes Tax Taxes Taxes Income-Indexed 1977 Tax Law First b/ -0.6 3.9 1.1 3.8 8.2 Second -0.7 4.6 1.1 3.6 8.7 Third 1.5 6.8 1.3 2.2 11.8 Fourth 3.9 7.4 1.6 2.1 14.9 Fifth 5.8 7.7
  • Principles and Policy: a Guide to California's Tax System

    Principles and Policy: a Guide to California's Tax System

    SPECIAL REPORT IN PRINCIPLES AND POLICY: A GUIDE TO CALIFORNIA’S TAX SYSTEM April 2013 A Publication of the California Budget Project California Budget Project This report was initially written by former executive director Jean Ross and was updated by Alissa Anderson and Samar Lichtenstein. The CBP was founded in 1994 to provide Californians with a source of timely, objective, and accessible expertise on state fi scal and economic policy issues. The CBP engages in independent fi scal and policy analysis and public education with the goal of improving the economic and social well-being of low- and middle-income Californians. Support for the CBP comes from foundation grants, subscriptions, and individual contributions. Please visit the CBP’s website at www.cbp.org. California Budget Project 1107 9th Street, Suite 310 Sacramento, CA 95814 P: (916) 444-0500 F: (916) 444-0172 [email protected] www.cbp.org Table of Contents Introduction: Why We Should Care 3 What Should a Good Tax System Do? 3 The Personal Income Tax 11 The Sales and Use Tax 13 The Corporate Income Tax 15 Other State Taxes 18 Tax Administration: Why It Matters 23 Constitutional and Voter-Enacted Constraints on Tax Policymaking 24 Conclusion: Issues and Options for Reform 24 Endnotes 26 Most simply, taxes are the way governments raise the revenues necessary to support public services. While INTRODUCTION: WHY WE there is little disagreement over the purpose of state and local taxes, there is considerable controversy over what SHOULD CARE constitutes an appropriate level of taxation and how state tax systems ought to be structured.
  • DISCUSSION PAPER SERIES Top Incomes in Germany, 1871-2014

    DISCUSSION PAPER SERIES Top Incomes in Germany, 1871-2014

    DISCUSSION PAPER SERIES IZA DP No. 11838 Top Incomes in Germany, 1871-2014 Charlotte Bartels SEPTEMBER 2018 DISCUSSION PAPER SERIES IZA DP No. 11838 Top Incomes in Germany, 1871-2014 Charlotte Bartels DIW Berlin, UCFS and IZA SEPTEMBER 2018 Any opinions expressed in this paper are those of the author(s) and not those of IZA. Research published in this series may include views on policy, but IZA takes no institutional policy positions. The IZA research network is committed to the IZA Guiding Principles of Research Integrity. The IZA Institute of Labor Economics is an independent economic research institute that conducts research in labor economics and offers evidence-based policy advice on labor market issues. Supported by the Deutsche Post Foundation, IZA runs the world’s largest network of economists, whose research aims to provide answers to the global labor market challenges of our time. Our key objective is to build bridges between academic research, policymakers and society. IZA Discussion Papers often represent preliminary work and are circulated to encourage discussion. Citation of such a paper should account for its provisional character. A revised version may be available directly from the author. IZA – Institute of Labor Economics Schaumburg-Lippe-Straße 5–9 Phone: +49-228-3894-0 53113 Bonn, Germany Email: [email protected] www.iza.org IZA DP No. 11838 SEPTEMBER 2018 ABSTRACT Top Incomes in Germany, 1871-2014* This study provides new evidence on top income shares in Germany from the period of industrialization to the present. Income concentration was high in the nineteenth century, dropped sharply after World War I and during the hyperinflation years of the 1920s, and increased rapidly throughout the Nazi period beginning in the 1930s.
  • A Global Philanthropy Legal Environment Index

    A Global Philanthropy Legal Environment Index

    Rules to Give By A Global Philanthropy Legal Environment Index Initiated by Nexus; legal research conducted by McDermott Will & Emery LLP; analysis provided by Charities Aid Foundation, Nexus and McDermott Will & Emery LLP. Written by Elaine Quick Toni Ann Kruse Adam Pickering Contents Acknowledgments 4 About the Partners 5 Forewords 6 Rules to Give By Index Map 8 Executive Summary 10 Scope and Limitations of the Study 12 Scoring the Rules to Give By Index 14 Questions and Scoring 14 Exempt Countries 14 Analysis 15 Findings 17 Rules to Give By Index 17 Analyzing Index Scores 25 Income Level 26 Regional Breakdown 28 Non-Profit Organizations 30 Tax Exemption 30 Reporting Requirements 30 Impact of Legal Structure on Giving 33 Tax Incentives 34 Effectiveness of Tax Incentives for Individuals 38 Different Incentives for Corporations and Individuals 40 Estate Taxes and Incentives for Legacy Donations 41 Rules to Give By Index in Alphabetical Order 43 Rules to Give By Country Reports 51 Disclaimer 294 Rules to Give By: A Global Philanthropy Legal Environment Index 3 Nexus | McDermott Will & Emery | Charities Aid Foundation Acknowledgements Nexus would like to thank Alessandra Gregg, Clyde McConaghy, Elaine Quick, Yulya Spantchak, and Jonah Wittkamper. We are immensely grateful to McDermott Will & Emery LLP and the Charities Aid Foundation (“CAF”) for their dedication and the extensive resources they have committed to making this report possible. In particular we would like to thank Toni Ann Kruse, who led a team of over 70 attorneys at McDermott Will & Emery LLP in preparation of the Index to this report, and Adam Pickering at CAF, who led the analysis of the data compiled in the Index.
  • The Things of Caesar: Mark-Ing the Plural (Mk 12:13–17)

    The Things of Caesar: Mark-Ing the Plural (Mk 12:13–17)

    Page 1 of 9 Original Research The Things of Caesar: Mark-ing the Plural (Mk 12:13–17) Author: This article observes the rarely-discussed phenomenon that the Marcan paying-the-tax scene 1,2 Warren Carter refers to tax in the singular, whilst the concluding saying uses the plural ‘the things of Caesar Affiliations: and of God’. The article accounts for this phenomenon by means of developing traditions. 1Brite Divinity School, The section under the heading ‘Mark’s scene and saying about taxes (12:13–17)’ counters Texas Christian University, the common claim that scene and saying originated as a unit from the historical Jesus. It United States of America proposes that whilst the saying may have originated with Jesus, the scene as we have it did 2Department of New not. The section under the heading ‘Social memory, orality, and a multi-referential saying?’ Testament Studies, Faculty suggests some contexts that the saying about the things of Caesar addressed pre-Mark. And of Theology, University of under the section ‘Trauma and Mark’s scene’ it is argued that Mark created a unit comprising Pretoria, South Africa scene and saying to negotiate the ‘trauma’ of the 66–70 war. The unit evaluates freshly- Note: asserted Roman power as idolatrous and blasphemous whilst simultaneously authorising Prof. Dr Warren Carter is the continued involvement of Jesus-believers in imperial society. participating as a research associate in the project ‘Biblical Theology and Hermeneutics’, directed Introduction by Prof. Dr Andries G. Van Aarde, honorary professor Despite extensive discussion of the Synoptic paying-the-tax scene (Mk 12:13–17), little attention in the Faculty of Theology, has been paid to the incongruity between linguistic items in the singular – tax (κῆσον,1 Mk 12:14), University of Pretoria, denarius (δηνάριον) (Mk 12:15) – and Jesus’ final saying that employs the plural, ‘the things’ τά( ) South Africa.
  • To View a PDF of This Article, Please Click Here

    To View a PDF of This Article, Please Click Here

    GLOBAL TAX WEEKLY ISSUE 223 | February 16, 2017 a closer look SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL FISCAL GOVERNANCE BUDGETS COMPLIANCE OFFSHORE SECTORS MANUFACTURING RETAIL/WHOLESALE INSURANCE BANKS/FINANCIAL INSTITUTIONS RESTAURANTS/FOOD SERVICE CONSTRUCTION AEROSPACE ENERGY AUTOMOTIVE MINING AND MINERALS ENTERTAINMENT AND MEDIA OIL AND GAS COUNTRIES AND REGIONS EUROPE AUSTRIA BELGIUM BULGARIA CYPRUS CZECH REPUBLIC DENMARK ESTONIA FINLAND FRANCE GERMANY GREECE HUNGARY IRELAND ITALY LATVIA LITHUANIA LUXEMBOURG MALTA NETHERLANDS POLAND PORTUGAL ROMANIA SLOVAKIA SLOVENIA SPAIN SWEDEN SWITZERLAND UNITED KINGDOM EMERGING MARKETS ARGENTINA BRAZIL CHILE CHINA INDIA ISRAEL MEXICO RUSSIA SOUTH AFRICA SOUTH KOREA TAIWAN VIETNAM CENTRAL AND EASTERN EUROPE ARMENIA AZERBAIJAN BOSNIA CROATIA FAROE ISLANDS GEORGIA KAZAKHSTAN MONTENEGRO NORWAY SERBIA TURKEY UKRAINE UZBEKISTAN ASIA-PAC AUSTRALIA BANGLADESH BRUNEI HONG KONG INDONESIA JAPAN MALAYSIA NEW ZEALAND PAKISTAN PHILIPPINES SINGAPORE THAILAND AMERICAS BOLIVIA CANADA COLOMBIA COSTA RICA ECUADOR EL SALVADOR GUATEMALA PANAMA PERU PUERTO RICO URUGUAY UNITED STATES VENEZUELA MIDDLE EAST ALGERIA BAHRAIN BOTSWANA DUBAI EGYPT ETHIOPIA EQUATORIAL GUINEA IRAQ KUWAIT MOROCCO NIGERIA OMAN QATAR SAUDI ARABIA TUNISIA LOW-TAX JURISDICTIONS ANDORRA ARUBA BAHAMAS BARBADOS BELIZE BERMUDA BRITISH VIRGIN ISLANDS CAYMAN ISLANDS COOK ISLANDS CURACAO GIBRALTAR GUERNSEY ISLE OF MAN JERSEY LABUAN LIECHTENSTEIN MAURITIUS MONACO TURKS AND CAICOS ISLANDS VANUATU GLOBAL TAX WEEKLY a closer look Global Tax Weekly – A Closer Look Combining expert industry thought leadership and team of editors outputting 100 tax news stories a the unrivalled worldwide multi-lingual research week. GTW highlights 20 of these stories each week capabilities of leading law and tax publisher Wolters under a series of useful headings, including industry Kluwer, CCH publishes Global Tax Weekly –– A Closer sectors (e.g.
  • 69-88 Houtman Et Al F6.Indd

    69-88 Houtman Et Al F6.Indd

    The Actuality of Sacrifijice Past and Present Edited by Alberdina Houtman Marcel Poorthuis Joshua Schwartz Yossi Turner LEIDEN | BOSTON This is a digital offfprint for restricted use only | © 2014 Koninklijke Brill NV Contents List of Figures viii List of Contributors xi Introduction 1 Part 1 Archaeology and the Hebrew Bible 1 Conspicuous Destruction and the Economy of Sacrifijice in the Bronze and Early Iron Age East Mediterranean 9 Louise A. Hitchcock 2 Reading as an Act of Offfering: Reconsidering the Genre of Leviticus 1 34 Dorothea Erbele-Küster 3 The Death of Moses as a Sacrifijice of Atonement for the Sins of Israel: A Hidden Biblical Tradition 47 David Frankel Part 2 New Testament and post-Biblical Judaism 4 ‘So the Sons are Free’: The Temple Tax in the Matthean Community 71 Eric Ottenheijm 5 Sacrifijice in the Dead Sea Scrolls 89 Lawrence H. Schifffman 6 Jesus Christ, High Priest and Sacrifijice according to the Epistle to the Hebrews 107 Adelbert Denaux 7 Sacrifijice without the Rabbis: Ritual and Sacrifijice in the Second Temple Period according to Contemporary Sources 123 Joshua Schwartz This is a digital offfprint for restricted use only | © 2014 Koninklijke Brill NV vi contents Part 3 Early Christianity and Rabbinic Literature 8 Sacrifijice in ‘Gnostic’ Testimonies of the Second and Third Centuries ce 153 Riemer Roukema 9 Sacrifijice as Concession in Christian and Jewish Sources: The Didascalia Apostolorum and Rabbinic Literature 170 Marcel Poorthuis 10 Putting One’s Life on the Line: The Meaning of heʿerah lamavet nafsho and Similar Expressions 192 Alberdina Houtman 11 Ritual is with People: Sacrifijice and Society in Palestinian Yoma Traditions 206 Michael D.